# MOODY SECURITIES, LLC X-17A-5 (2019-03-01) — Broker-dealer annual report - Company: MOODY SECURITIES, LLC - Form: X-17A-5 - Filed: 2019-03-01 - Period: 2018-12-31 - Accession: 0001448683-19-000001 - CIK: 1448683 - File #: 8-68069 - Material weakness: No - Auditor: Frazier & Deeter, LLC - Auditor location: Atlanta, GA - Contact: Robert Engel - Phone: 713-977-7500 - Signed by: Robert Engel (Chief Financial Officer) Original filing: https://www.sec.gov/Archives/edgar/data/1448683/000144868319000001/moodysecurities.pdf --- {0}------------------------------------------------ ## FINANCIAL STATEMENTS AND SUPPLEMENTARY INFORMATION REQUIRED BY SEC RULE 17a-5 #### DECEMBER 31, 2018 {1}------------------------------------------------ # *Table of Contents* #### *December 31,2018* | Annual Audited Report Form X-17a-5 Part III Facing Page | I -
2 | |----------------------------------------------------------------------------------------------------|----------| | Report oflndependent Registered Public Accounting Firm on Financial Statements | 3-4 | | Statement ofFinancial Condition | 5 | | Statement of Operations | 6 | | Statement of Changes in Member's Equity | 7 | | Statement of Cash Flows | 8 | | Notes to Financial Statements | 9-
13 | | Supplemental Information: | | | Schedule I: Net Capital Computation Under Rule 15c3-1 of the
Securities and Exchange Commission | 14 | | Schedule II: Exemption from SEC Rule 15c3-3 | 15 | | | | | Rep01t of Independent Registered Public Accounting Firm on Exemption Report | 16 | | Exemption Report | 17 | {2}------------------------------------------------ UNITEDST ATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 | ANNUAL AUDITED REPORT | | | | | |-----------------------|--|--|--|--| | FORM X-17 A-5 | | | | | | PART Ill | | | | | OMB APPROVAL OMB Number: 3235-0123 Expires: August 31, 2020 Estimated average burden hours per response ...... 12.00 | SEC FILE NUMBER | |-----------------| | B-68069 | #### FACING PAGE Information Required of Brokers and Dealers Pursuant to Section 17 of the Securities Exchange Act of 1934 and Rule 17a-5 Thereunder | REPORT FOR THE PERIOD BEGINNING 01/01/2018 | | | AND ENDING 12/31/2018
----------------------- | | |----------------------------------------------|--------------------------------------------------------------------------|---------|--------------------------------------------------|--| | | MM/DD/YY | | MM/DD/YY | | | | A. REGISTRANT IDENTIFICATION | | | | | NAME oF BROKER-DEALER: Moody Securities, LLC | | | OFFICIAL USE ONLY | | | | ADDRESS OF PRINCIPAL PLACE OF BUSINESS: (Do not use P.O. Box No.) | | FIRM I.D. NO. | | | 6363 Woodway, Suite 110 | | | | | | | (No. and Street) | | | | | Houston | Texas | | 77057 | | | (City) | (State) | | (Zip Code) | | | Robert Engel | NAME AND TELEPHONE NUMBER OF PERSON TO CONTACT IN REGARD TO THIS REPORT | | | | | | | | (Area Code- Telephone Number) | | | | B. ACCOUNTANT IDENTIFICATION | | | | | | INDEPENDENT PUBLIC ACCOUNTANT whose opinion is contained in this Report* | | | | | Frazier & Deeter, LLC | | | | | | | (Name- if individual. state last. first. middle name) | | | | | 1230 Peachtree Street, Suite 1500 Atlanta | | Georgia | 30309 | | | (Address) | (City) | (State) | (Zip Code) | | | CHECK ONE: | | | | | | /'
J Certified Public Accountant
J | | | | | | DPublic Accountant | | | | | | D | Accountant not resident in United States or any of its possessions. | | | | | | FOR OFFICIAL USE ONLY | | | | | | | | | | | | | | | | *\*Claims for exemption from the requirement that the annual report be covered by the opinion of an independent public accountant must be supported by a statement of facts and circumstances relied on as the basis for the exemption. See Section 240.17a-5(e)(2)* > Potential persons who are to respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB control number. {3}------------------------------------------------ #### **OATH OR AFFIRMATION** | 1, Robert Engel | | , swear (or affirm) that, to the best of | |-----------------|------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | d~y_S
rit ie | | my knowledge and belief the accompanying financial statement and supporting schedules pertaining to the firm of
Lc _______________________________________________________________________ , as | | of December 31 | __
. 20
18 | :; . are true and correct. I further swear (or affirm) that | neither the company nor any partner, proprietor, principal of1icer or director has any propl'ietary interest in any account classified solely as that of a customer, except as follows: | I
LI.Wf C. ARAGON
My Notary 101128211941
Chief Financial Officer
ExphsApr114, 2022
Title | 'ignawre(:) | |-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------| | This report H contains (check all applicable boxes):
0 (a) Facing Page.
{b) Statement of Finuncial Condition.
(c) Statement of Income (Loss).
(d) Stutement of Changes in Financial Condition.
(e) Statement of Changes in Stockholders' Equity or Partners' or Sole Proprietors' Capital.
(f) Statement of Changes in Liabilities Subordinated to Claims of Creditors.
(g) Computation of Net Capital.
(h) Computation for Determination of Reserve Requirements Pursuant to Rule 15c3-3.
{i) Information Relating to the Possession or Control Requirements Under Rule 15c3-3.
0 (j)
A Reconciliation, including appropriate explanation of the Computation of Net Capital Under Rule 15c3-l and the
Computation for Determination of the Reserve Requirements Under Exhibit A of Rule 15c3-3.
0 (k) A Reconciliation between the audited and unaudited Statements of Financial Condition with respect to methods of
consolidation.
.~ (I) An Oath or Affirmation.
(m) A copy of the SIPC Supplemental Report.
~
(n) A rep01t describing any material inadequacies found to exist or found to have existed since thedateofthe previous audit. | | *U.For conditiom of confidential treatment of certain portions of this filing, see section 240.17a-5(e)(3).* {4}------------------------------------------------ ![](_page_4_Picture_0.jpeg) 1230 Peachtree Street NE Suite 1500 Atlanta, Georgia 30309 404.253.7500 #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Manager and Member of Moody Securities, LLC #### Opinion on the Financial Statements We have audited the accompanying statement of financial condition ofMoody Securities, LLC, {the "Company") as ofDecember 31,2018, and the related statements of operations, changes in member's equity and cash flows for the year then ended, and the related notes and schedules (collectively referred to as the financial statements). In our opinion, the financial statements present fairly, in all material respects, the financial position ofthe Company as ofDecember 31,2018, and the results of its operations and cash flows for the year then ended in conformity with accounting principles generally accepted in the United States of America. #### Basis for Opinion These financial statements are the responsibility of the Company's management. Our responsibility is to express an opinion on the Company's financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB") and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations ofthe Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud. The Company is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audit we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial reporting. Accordingly, we express no such opinion. Our audit included performing procedures to assess the risks of material misstatement ofthe financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. ![](_page_4_Picture_10.jpeg) Page 3 ![](_page_4_Picture_12.jpeg) ![](_page_4_Picture_13.jpeg) {5}------------------------------------------------ #### **Supplemental Information** The information included in the supplemental schedules has been subjected to audit procedures performed in conjunction with the audit ofMoody Securities, LLC's financial statements. The supplemental information is the responsibility of Moody Securities, LLC's management. Our audit procedures included determining whether the supplemental information reconciles to the financial statements or the underlying accounting and other records, as applicable, and performing procedures to test the completeness and accuracy of the information presented in the supplemental information. In forming our opinion on the supplemental information, we evaluated whether the supplemental information, including its form and content, is presented in conformity with Rule 17a-5 of the Securities Exchange Act of 1934. In our opinion, the supplemental information is fairly stated, in all material respects, in relation to the financial statements as a whole. We have served as the Company's auditor since 2012. Atlanta, Georgia February 26, 2019 {6}------------------------------------------------ # *Statement of Financial Condition* ## *December 31, 2018* | Assets | | |-----------------------------------------------------------------|--------------------------| | Cash
Prepaid expenses | \$
385,472
374,153 | | Total Assets | \$ 759,625 | | Liabilities and Member's Equity | | | Accounts payable and accrued expenses
Due to related parties | \$
188,805
22,000 | | Total liabilities | 210,805 | | Commitments and contingencies | | | Member's equity | 548,820 | | Total Liabilities and Member's Equity | \$ 759,625 | {7}------------------------------------------------ # *Statement of Operations* #### *For the Year Ended December 31,2018* | Revenues | 7,411,018
\$ | |------------------------------|-------------------| | Operating expenses: | | | Commissions | 6,520,443 | | General and administrative | 1,835,684 | | Management fees | 120,000 | | Registration and filing fees | 37,895 | | Legal and professional fees | 293,508 | | Payroll and related taxes | 1,886,850 | | Total operating expenses | 10,694,380 | | Net loss | (3,283,362)
\$ | {8}------------------------------------------------ # *Statement of Changes in Member's Equity* #### *For the Year Ended December 31,2018* | | Total
Member's
Equity | |------------------------------|-----------------------------| | Balance at January 1, 20 18 | \$
388,382 | | Member cash contributions | 3,443,800 | | Net loss | (3,283,362) | | Balance at December 31, 2018 | 548,820
\$ | {9}------------------------------------------------ # *Statement of Cash Flows* #### *For the Year Ended December 31, 2018* | Cash flows from operating activities:
Net loss
Adjustments to reconcile net loss to net cash used in operating activities:
Changes in operating assets and liabilities: | \$ | (3,283,362) | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|-----------------------------------| | Prepaid expenses
Accounts payable and accrued expenses
Due to related parties | | (188,137)
I 09,244
(14,750) | | Net cash used in operating activities | | (3,377,005) | | Cash flows from financing activities:
Member cash contributions | | 3,443,800 | | Net cash provided by financing activities | | 3,443,800 | | Net increase in cash | | 66,795 | | Cash-
beginning ofyear | | 318,677 | | end of year
Cash - | \$ | 385,472 | | Non-cash operating transactions:
Accrued prepaid insurance premiums | \$ | 55,831 | {10}------------------------------------------------ # *Notes to Financial Statements- Continued* # *December 31, 2018* Note I - General information and summary of significant accounting policies: #### Description ofbusiness Moody Securities, LLC (the "Company") was formed on September 21, 2007, as a Delaware Limited Liability Company for the purpose of providing financial services primarily to entities related to its sole member. The Company is a broker-dealer of securities under the Securities Exchange Act of 1934 and is a member of the Financial Industry Regulatory Authority ("FINRA"). To date, the Company has received its funding from contributions from its sole member and its continued existence, in the absence of adequate cash flows from operations or other sources, will be dependent on receiving continued support from its member. The Company is the dealer manager of Moody National REIT II, Inc.'s ("REIT II") public offering. The Company receives a selling commission of up to 6.0% of gross offering proceeds raised in REIT IJ's public offering, all or a portion of which could be re-allowed to participating broker-dealers. In addition, REIT II pays the Company a dealer manager fee of up to 2.5% of gross offering proceeds raised in REIT II's public offering, a portion of which could be re-allowed to participating broker-dealers. No selling commissions or dealer manager fee are paid for sales pursuant to REIT JI's dividend reinvestment plans. The Company is also the dealer manager of Moody National Academy DST's ("Academy DST"), Moody DFW DST's ("DFW DST") and Moody Village One DST's ("Village One DST") offerings of beneficial ownership interests. The Company receives a selling commission of up to 6.0% of gross offering proceeds raised in Academy DST's, DFW DST's, and Village One DST's offerings, all or a portion ofwhich could be re-allowed to participating broker-dealers. In addition, Academy DST, DFW DST and Village One DST pay the Company a non-accountable marketing and due diligence allowance equal to I% of gross offering proceeds raised in Academy DST's, DFW DST's and Village One DST's offerings, a p01iion of which could be re-al lowed to participating broker-dealers. The Company also receives a placement fee equal to 0.5% of gross offering proceeds raised in Academy DST's offering and receives a placement fee equal to 1.0% of gross offering proceeds raised in DFW DST's and Village One DST's offerings. The Company may sell beneficial ownership interests in Academy DST, DFW DST and Village One DST as a selling group member, thereby becoming entitled to selling commissions. The total aggregate amount of selling commissions, allowances, and expense reimbursements will not exceed 7.5% of gross offering proceeds raised in Academy DST's offering or 8.0% in DFW DST's and Village One DST's offerings. {11}------------------------------------------------ ## *Notes to Financial Statements- Continued* ## *December 31, 2018* #### Basis of presentation The Company has adopted the Financial Accounting Standards Board ("F ASB") Codification ("Codification"). The Codification is the single official source of authoritative accounting principles generally accepted in the United States of America (U.S. GAAP) recognized by the FASB to be applied by nongovernmental entities. All of the Codification's content carries the same level of authority. #### Use of estimates The preparation of financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates. The Company considers all short-term highly liquid investments which are readily convertible into cash and have maturities as ofthe date of purchase ofthree months or less to be cash equivalents. #### Income taxes The Company was formed as a limited liability company and is treated as a partnership for federal income tax purposes. The earnings and losses of the Company are included in the member's income tax return. Consequently, the Company's income or loss is presented without a provision for federal and state income taxes. The Company's income or loss is allocated to the member in accordance with the organizational agreement. The Company recognizes the tax benefit from an uncertain tax position only if it is more likely than not that the tax position will be sustained on examination by the taxing authority, based on the technical merits of the position. The Company does not file composite state income tax returns. All federal and state income tax positions taken or anticipated to be taken in the income tax returns are attributable to the member and not to the Company. As of December 31, 2018, there are no known items which would result in a material accrual related to where the Company has federal or state attributable tax positions. {12}------------------------------------------------ ## *Notes to Financial Statements- Continued* ## *December 31, 2018* #### Revenue recognition policy The Company earns revenue through various investment banking activities primarily as an advisor in services related to debt and equity securities offerings. Commissions and management fee revenues are generally earned and recognized only upon successful completion of the transaction. A securities transaction is deemed complete when the investor's funds are received by the issuer and all other terms of the subscription agreement have been met. In May 2014, the FASB issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), or ASU 606. ASU 606 provides guidance outlining a single comprehensive model for entities to use in accounting for revenue arising from contracts with customers that supersedes most current revenue recognition guidance. This guidance requires the Company to recognize revenue when promised goods or services are transferred to customers in an amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services. The original effective date of the guidance would have required the Company to adopt at the beginning of fiscal 20 17; however, the F ASB approved an optional one-year deferral of the effective date. Additionally, the new guidance requires enhanced disclosures, including revenue recognition policies to identify performance obligations to customers and significant judgments in measurement and recognition. The new guidance may be applied retrospectively to each prior period presented or retrospectively with the cumulative effect recognized as of the date of adoptions. The Company adopted the new guidance effective January 1, 2018 which did not require any change in the timing of the recognition ofthe Company's revenue. #### Financial instruments and credit risk The financial instrument which potentially subjects the Company to credit risk is cash. The Company maintains its cash with a major domestic bank. From time to time, cash may exceed federally insured limits. The Company has not incurred losses related to these deposits. #### Fair value of financial instruments The Company's financial instruments consist of cash. The carrying amount of cash approximates fair value because of the short-term nature ofthis item. {13}------------------------------------------------ #### *Notes to Financial Statements- Continued* #### *December 31, 2018* #### Note 2 - Related party transactions: Effective January I, 2016, the Company entered into a management agreement with a Company affiliated with its sole member through common ownership structured in accordance with the broker-dealer expense reporting provisions established by the U.S. Securities and Exchange Commission ("SEC"). On July 1, 2016, the Company entered into a new management agreement with a Company affiliated with its sole member on the same terms and conditions as the January I, 2016 agreement. The agreement automatically renews on an annual basis and includes furnishing of office space, supplies and equipment and facilitating the Company's payroll, insurance and employee benefits function. The Company paid \$120,000 in management fees to this affiliate during the year ended December 31, 2018. Effective January I, 2016, the Company entered into a sublease agreement with an affiliate to lease office space in Houston, Texas for \$1,000 per month. Total rent expense related to this agreement for the year ended December 31, 2018 was \$12,000. The sublease agreement terminated on December 31, 2018 and continued on a month-to-month basis. The Company received all of its revenue of \$7,411,018 for the year ended December 31, 2018 from REIT II, Academy DST, DFW DST and Village One DST. #### Note 3 - Consulting agreement: During January 2009, the Company entered into a consulting services agreement with MGL Consulting Corporation ("MGL") to provide bookkeeping services and FINRA compliance services. The agreement automatically renews on an annual basis until terminated by either party. The agreement includes a fixed monthly professional fee of \$8,070 per month, plus additional professional fees regarding financial bookkeeping and regulatory compliance, which are billed based on MGL's fixed fee contract. Consulting fees paid to MGL were approximately \$198,000 for the year ended December 31, 2018. {14}------------------------------------------------ ## *Notes to Financial Statements- Continued* ## *December 31, 2018* #### Note 4 -Net capital requirements: In accordance with Rule 15c3-1 ofthe SEC, the Company's aggregate indebtedness, as defined, shall not exceed 15 times its net capital. The Company must also maintain minimum net capital. As ofDecember 31,2018, the Company's net capital, as defined, of\$174,667 exceeded the required minimum of \$14,054 by \$160,613 and its ratio of aggregate indebtedness to net capital was 1 .2069 to 1.0. #### Note 5 - Insurance note payable: The Company finances its annual broker-dealer professional liability insurance premiums. The Company records a corresponding prepaid asset upon financing. During 2018, the Company accrued insurance premiums of\$55,831 and made premium payments of\$55,831. #### Note 6 -Subordinated liabilities: There were no liabilities subordinated to claims of general creditors at any time during the year. Therefore, the statement of changes in liabilities subordinated to claims of general creditors has not been presented for the year ended December 31, 2018. #### Note 7 - Subsequent events: Management has evaluated subsequent events as of February 26, 2019, which is the date that the financial statements were available for issuance, and has determined that there are no subsequent events to be reported. {15}------------------------------------------------ #### SUPPLEMENTAL INFORMATION {16}------------------------------------------------ #### *Schedule I: Net Capital Computation Under Rule 15c3-l of the Securities and Exchange Commission* #### *For the Year Ended December 31, 2018* | Net capital requirement, the greater of:
1/15 of Aggregate Indebtedness
Minimum Dollar Requirement | \$ | 14,054
5,000 | \$
14,054 | |----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----|-----------------|------------------------------------------| | Net capital | | | 174,667 | | Excess Net Capital: | | | \$
160.613 | | Aggregate indebtedness | | | \$
210,805 | | Excess net capital @ I 00%
(Net capital, less I 0% aggregate indebtedness) | | | \$
153.586 | | Ratio of aggregate indebtedness to net capital | | | 120.69% | | Ratio of subordinated indebtedness to debt/equity total | | | NIA | | Total assets | | | \$
759,625 | | Less -total liabilities | | | 210,805 | | Net worth
Deductions from and/or charges to net worth:
Total non-allowable assets
Other deductions or charges
Total deductions fi·om net worth
Net capital before haircuts on securities positions:
Haircuts on securities
Certificates of deposit and commercial paper | | 374,153 | 548,820
374,153
374,153
174,667 | | U.S. and Canadian government obligations
State and municipal government obligations
Corporate obligations
Stock and warrants
Options
Arbitrage
Other securities
Undue concentration | | | | | Net capital | | | \$
174,667 | | Reconciliation with the Company's Computation (included in
Part II of Form X-17-A-5) as of December 31,2018: | | | | | Net capital, as reported in the Company's Part II (unaudited):
Focus Report
Audit adjustments: | | | \$
174,667 | | Net capital, per above | | | \$
174.667 | See independent auditor's report {17}------------------------------------------------ *Schedule II: Exemption From SEC Rule 15c3-3* *For the Year Ended December 31, 2018* Note: The Company operates pursuant to the (k)(2)(i) exemption provisions of SEC Rule l5c3-3. See independent auditor's report {18}------------------------------------------------ ![](_page_18_Picture_0.jpeg) 1230 Peachtree Street NE Suite 1500 Atlanta, Georgia 30309 404 253.7500 #### REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Management of Moody Securities, LLC We have reviewed management's statements, included in the accompanying Moody Securities, LLC's Exemption Report, in which (1) Moody Securities, LLC identified the following provisions of 17 C.P.R. § 15c3-3(k) under which Moody Securities, LLC claimed an exemption from 17 C.F .R. §240.15c3-3: (2)(i) (the "exemption provisions") and (2) Moody Securities, LLC stated that Moody Securities, LLC met the identified exemption provisions throughout the most recent fiscal year without exception. Moody Securities, LLC's management is responsible for compliance with the exemption provisions and its statements. Our review was conducted in accordance with the standards of the Public Company Accounting Oversight Board (United States) and, accordingly, included inquiries and other required procedures to obtain evidence about Moody Securities, LLC's compliance with the exemption provisions. A review is substantially less in scope than an examination, the objective of which is the expression of an opinion on management's statements. Accordingly, we do not express such an opinion. Based on our review, we are not aware of any material modifications that should be made to management's statements referred to above for them to be fairly stated, in all material respects, based on the provisions set forth in paragraph (k)(2)(i) of Rule 15c3-3 under the Securities Exchange Act of 1934. Atlanta, Georgia February 26, 2019 ![](_page_18_Picture_9.jpeg) Page 16 ![](_page_18_Picture_11.jpeg) {19}------------------------------------------------ #### **Moody Securities, LLC's Exemption Report** Moody Securities, LLC (the "Company") is a registered broker-dealer subject to Rule 17a-5 promulgated by the Securities and Exchange Conm1ission (17 C.F.R. §240.17a-S, "Reports to be made by certain brokers and dealers"). This Exemption Report was prepared as required by 17 C.F.R. § 240.17a-5(d)(l) and (4). To the best of its knowledge and belief, the Company states the following: - 1. Moody Securities, LLC claimed an exemption 17 C.F.R. § 240.15c3-3 under the following provisions of 17 C.F.R. § 240.15c3-3 (k)(2)(i) for the fiscal year ended December 31,2018. - 2. Moody Securities, LLC met the identified exemption provisions in 17 C.F.R. § 240.15c3- 3(k)(2)(i) throughout the most recent fiscal year of January 1, 2018 to December 31,2018, without exception. Moody Securities, LLC I, Robert Engel, affirm that, to my best knowledge and belief, this Exemption Report is true and correct. | Signature | | | |-----------|-----|--| | | (fo | | | | | | Title February 26, 2019 Source: SEC EDGAR via Adviser Search (https://search.stillhousedata.com). Agents: see https://search.stillhousedata.com/llms.txt.